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Taxation-Federal Estate and Gift Commons

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Full-Text Articles in Taxation-Federal Estate and Gift

Unauthorized Tax Elections, Jay A. Soled Jul 2022

Unauthorized Tax Elections, Jay A. Soled

Buffalo Law Review

Unauthorized tax elections are those devices and techniques that taxpayers employ to achieve sought-after objectives but that are not specifically endorsed under the Internal Revenue Code. Often evolving over time, they are a common feature of the nation’s tax system. While unauthorized tax elections can prove subversive, in many instances, if properly and timely addressed, their existence can produce salutary benefits vis-à-vis their eradication or formal institutionalization.

This analysis explores the general contours of unauthorized tax elections and the critical signaling roles that they provide, alerting Congress and the Treasury Department to shortcomings and vulnerabilities in the Internal Revenue Code’s …


Patenting The Tax Code: Monopolizing Basic Tax Strategy, Nicholas Robinson Oct 2007

Patenting The Tax Code: Monopolizing Basic Tax Strategy, Nicholas Robinson

Buffalo Intellectual Property Law Journal

No abstract provided.


The New Estate And Gift Tax Regime, John Y. Taggart Oct 1982

The New Estate And Gift Tax Regime, John Y. Taggart

Buffalo Law Review

No abstract provided.


Inherited Excess Mortgage Property: Death And The Inherited Tax Shelter, Louis A. Del Cotto, Kenneth F. Joyce Jan 1979

Inherited Excess Mortgage Property: Death And The Inherited Tax Shelter, Louis A. Del Cotto, Kenneth F. Joyce

Journal Articles

No abstract provided.


The Application Of Section 2036 To Inter Vivos Transfers Of Stock In Closely-Held Corporations, George A. Neidich Jan 1973

The Application Of Section 2036 To Inter Vivos Transfers Of Stock In Closely-Held Corporations, George A. Neidich

Buffalo Law Review

No abstract provided.


Taxation—Treasury Regulation Valuing Mutual Fund Shares For Estate Tax Purposes At The Replacement Cost Held Invalid, James E. Brown Oct 1971

Taxation—Treasury Regulation Valuing Mutual Fund Shares For Estate Tax Purposes At The Replacement Cost Held Invalid, James E. Brown

Buffalo Law Review

Cartwright v. United States, 323 F. Supp. 769 (W.D.N.Y. 1971).


Federal Income Taxation Of Estates And Beneficiaries. By M. Carr Ferguson, James L. Freeland, And Richard B. Stephens, Ronald H. Jensen Jan 1971

Federal Income Taxation Of Estates And Beneficiaries. By M. Carr Ferguson, James L. Freeland, And Richard B. Stephens, Ronald H. Jensen

Buffalo Law Review

No abstract provided.


Taxation Of The Trust Annuity: The Unitrust Under The Constitution And The Internal Revenue Code, Louis A. Del Cotto, Kenneth F. Joyce Mar 1968

Taxation Of The Trust Annuity: The Unitrust Under The Constitution And The Internal Revenue Code, Louis A. Del Cotto, Kenneth F. Joyce

Journal Articles

No abstract provided.


Taxation—Apportionment Of Estate Taxes Among Individual And Charitable Legatees, Walter W. Miller Jr. Oct 1962

Taxation—Apportionment Of Estate Taxes Among Individual And Charitable Legatees, Walter W. Miller Jr.

Buffalo Law Review

In the Matter of the Will of Shubert, 10, N.Y.2d 461, 180 N.E.2d 410, 225 N.Y.S. 2d 13 (1962).